The Tax Court properly concluded that it lacked jurisdiction over taxpayers’ petition because the taxpayers did not file it within 90 days of a notice of deficiency or 30 days of a notice of determination, the Ninth Circuit Court of Appeals held. The court reject as meritless Taxpayers’ contentions that the Tax Court’s final decisions sustaining the deficiency for 1993 to 1995 were reached by fraud or mutual mistake. [Said v. Commissioner, No. 20-70223 (9th Cir. Feb. 22, 2021) (unpub. op.)]
View Source Document.